Letter sent to the City of Lethbridge and the Government of Canada regarding the use of pesticides and propose amendments to legislation protecting Canadians and the environment from negative impacts.
Dear Elected Officials,
The members of the Southern Alberta Group for the Environment (SAGE) are concerned by the proposed amendments to the Pest Control Products Act (PCPA) that were contained within Bill C-30, the Spring Economic Update 2026 Implementation Act, and Bill C-31, the Budget 2025 Implementation Act, No. 2.
For more than two decades, the PCPA was a foundation upon which Canadian pesticide regulators built science-based policy that prioritized human health and environmental protection. As the preamble to the Act states, “the availability and use of pest control products pose potential risks, both directly and indirectly, to the health, safety and wellbeing of individuals in Canada and to the environment.” The Act was a safeguard against unacceptable risks that would arise from the use of dangerous pesticides.
The amendments that were proposed in Bills C-30 and C-31 represent the largest overhaul of the Canadian pesticide regulatory system in a generation. We in SAGE are writing to you because the changes sabotage environmental and health protections and undermine public confidence in evidence-based regulation.
We are concerned
The proposed amendments would allow Cabinet to override science-based decisions made by the Minister of Health regarding pesticide risks. Bill C-30 would empower Cabinet to issue “emergency orders” and “economic security and food security orders” that could permit the continued use of pesticides even after the Minister has determined that they pose unacceptable environmental risk.
These provisions could motivate the permission of harmful pesticides to be distributed and sold and (ab)used for years, regardless of scientific evidence of environmental harm. Cabinet would be granted broad authority to overturn decisions that would deny emergency pesticide use or cancel pesticide registration because of unacceptable environmental risk. Such authority could allow environmentally harmful pesticides to remain in use for up to six years, followed by additional phase-out periods.
The existing Pest Control Products Regulations already permit emergency registrations when there is a seriously detrimental infestation and when health and environmental risks are supposedly “acceptable.” The members of SAGE do not see any reason at all that Cabinet was granted such extraordinary powers to circumvent the Act’s foundational requirement that pesticide use must not pose unacceptable risks.
Bill C-30 would also require the Minister of Health to consider undefined concepts such as “national economic security,” “regional economic security,” and “national food security” when making pesticide registration decisions. These phrases are not defined in the legislation and there is apparently no criterion to govern the method of the application of them to decision-making. The vagueness obviously permits the infiltration of industrial interests, where decision-making should be based on systematic reviews of scientific research.
The Act already included instructions regarding the hypothetical social and economic value of pest control products. The current lack of definitions and the lack of regulatory capacity could permit the contamination of the process by industrial priorities, which could overshadow the protection of human and environmental health.
Pesticides should be restrained by science
The members of SAGE are also concerned by the changes proposed in Bill C-31. Currently, there are mandatory cyclical re-evaluations of pesticides every 15 years, which ensure that regulatory decisions reflect the most recent findings of scientific research. The observation and quantification of environmental and health risks can be calculated (many) years after dangerous products are distributed and sold.
Bill C-31 would motivate the replacement of comprehensive reviews with limited assessments based only on the available information. Health Canada would be required to conduct a full re-evaluation only if an initial assessment indicates that risks have increased significantly.
We are concerned that this approach could allow grave health and environmental risks to persist undetected. The current re-evaluation process is the primary mechanism through which Health Canada obtains updated scientific data from registrants and other sources. The proposed methods for assessment would abandon the standards for information gathering and the opportunity for public participation.
We warn you that, as a result, dangerous pesticidal products could remain on the market for decades without comprehensive quantifications of risk that should be based on the precautionary principle and a systematic review of the science, including the very most recent studies.
An example of environmental consequences
For example, many people in Alberta are familiar with Richardson’s ground squirrels. While these animals can create challenges for landowners, poisoning them can also poison the predators that feed on them, including hawks, owls, eagles, foxes, coyotes, and snakes. Bioaccumulation of such poison can unravel food chains and devastate vulnerable and endangered species.
There are effective non-pesticidal alternatives available, including habitat management, cultural controls, biological controls, and the installation of raptor nesting platforms that encourage natural predation. Responsible people use the alternatives when they learn that ecosystems function while longstanding ecological relationships are maintained.
Under the conditions of diminished protections of Bills C-30 and C-31, highly toxic substances such as strychnine and other poisons could be more readily permitted under emergency-use provisions. Ghastly and toxic methods could damage the ecosystem with impacts that far outweigh the temporary relief of pest control.
Farm workers exposed
We are also disappointed by the recent decision by Health Canada to diminish health and safety protections for agricultural workers by making Safety Data Sheets optional under the PCPA.
Safety Data Sheets follow internationally recognized standards and provide information about chemical hazards, toxicities, first-aid measures, and product ingredients. They are required in many workplaces and work environments where hazardous substances are used.
The removal of this requirement places agricultural workers, particularly migrant farm workers, at unnecessary risk under the current diminished regulatory regime for pesticides. Without access to the basic facts about the chemicals they handle, workers cannot adequately protect themselves from exposure to hazardous pesticides.
The members of SAGE challenge the failure of Health Canada to enforce meaningful Safety Data Sheet requirements and we ask you to use your respective positions of decision-making power to restore these important protections.
The recommendation of SAGE
The members of SAGE ask our elected representatives to remove the proposed PCPA amendments from Bills C-30 and C-31 and recommit to the original purpose of the Pest Control Products Act: protecting human health, safety, and the environment. These substantial regulatory changes received no meaningful public consultation, despite the far-reaching implications. Neither Health Canada’s Science Advisory Group on Pesticide Regulation nor the Pest Management Advisory Committee was asked to provide advice on these measures. Rather than sitting back while the system of oversight of pesticides is sabotaged, we encourage you to improve the implementation of the existing Act and bolster the capacity of Health Canada to conduct science-based reviews.
In conclusion, we in SAGE represent many people in Alberta who care passionately about the betterment of human physical and mental health, and the health of all of our nonhuman neighbours in the ecosystem, and the health of future generations. With this communication, we alert you to the disastrous consequences of pesticide use and our hope that you will maintain rigorous scientific regulations.
We respectfully ask you to use the authority of your office to oppose the dangerous amendments to the Pest Control Products Act contained in Bills C-30 and C-31 and to advocate for regulatory decisions grounded in ecology and the public interest and not short-term political or economic considerations.
Please take a stand and demand that these provisions be removed.